T.C. Memo. 2003-190
UNITED STATES TAX COURT
DANNY AND RUTH KOSBAR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5371-02. Filed July 1, 2003.
Danny Kosbar and Ruth Kosbar, pro sese.
Bryan E. Sladek, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court under section
6404(h) to review respondent’s determination not to abate
interest for 1990 and 1991. Following respondent’s concession
that respondent will abate interest for the 3-day period from
June 20 through 22, 2001, we determine whether respondent abused
his discretion under section 6404 by not abating more of the
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